Most Recent Posts
Lois Lerner Out From Under Freedom Path Lawsuit For Now
In count IV, Freedom Path challenges as unconstitutional the IRS’s use of certain policies and procedures to target conservative organizations for heightened review of applications for tax-exempt status. Although the IRS’s adherence to these policies and procedures may ultimately culminate in a final decision regarding Freedom Path’s tax-exempt status, the use of these policies and procedures neither marks the consummation of the IRS’s decisionmaking process nor determines Freedom Path’s rights or obligations or precipitates legal consequences.
On Kent Hovind – Worth A Thousand Words
My friend and fellow Son of Xavier, John Sundman, author of techo thriller Acts of The Apostles (Not to be confused with the fantasy novel of the same title by somebody...
Will Christian Soldiers Be On The Streets Of Pensacola As Kent Hovind Goes To Trial?
The expert who gives me just a tad of optimism for Kent Hovind is William McGane who has written about lis pendens. Apparently lis pendens is a very privileged filing. The only way that filing one is fraudulent is if there is absolutely no sort of litigation to which it refers. Jury instruction that Hovind’s public defender is seeking focuses a lot on the element of willfulness and Hovind in his statements has been indicating that he is not that up on all the details. So a lack of willfulness defense just might work. The Hovindicators have been promoting jury nullification, so a hung jury is not out of the question.
IRS Denies 501(c)(3) Exemption To Booster Club Due To Inurement
Poking around on the internet it strikes me that this fundraising model was more prevalent in gymnastics than in other sports. That might be because if you are raising money for a baseball team or a band to go somewhere, you probably want to get the whole team there, since it won’t do the other players much good if all the pitchers or all the tuba players aren’t good at selling popcorn or whatever.
At any rate, the word seems to be getting out that this particular booster model does not work, if you are looking for exempt status. Dan Caldwell notes in his post 5 Essentials for Booster Clubs to Meet IRS Requirement that booster clubs cannot allocate to participants based on their fundraising efforts.
From The Boston Tax Institute
Lu Gauthier has given me permission to reproduce his email blasts. This one is a catch-up, so it is on the long side. Future posts in the series will be more focused....
Estate Intended For Charity Depleted By Litigation And Income Tax
The cautionary tale here is probably more about taking into account family issues and contingencies in estate planning for even relatively modest estates. Reading the state court decision, it appears that planning was done on the assumption that Ms. Belmont was going to outlive her brother and the implication of his being potentially made homeless in the event of her earlier death was not thought through.
What is really annoying about the outcome in this case is that the final return of the estate will pass through a useless deduction for administration expense to the charity. There is something odd about this mess ending up being a windfall for the treasury, but as Reilly’s First Law of Tax Planning goes – “It is what it is. Deal with it.”
Tom Cahill Recommends Happiness Project
The following is an open letter to Gretchen Rubin, author of "The Happiness Project: Or Why I Spent a Year Trying to Sing in the Morning, Clean My Closets, Fight Right,...
You And Your Shadow Do Not A Partnership Make
The key to Son-of-Boss was a paired currency option. When you contribute the paired option to the partnership you don’t treat your obligation to perform on one side as a liability, but you claim corresponding basis on the other side anyway. Essentially you have an unbalance entry, which is why normal accountants have such a hard time understanding the deals. Anyway without a partnership, you can’t even pretend that the whole things work.
I don’t think it is news that you can’t create a partnership with yourself and a disregarded entity, but it is a point that bears repeating. You can see it happening in the family limited partnership space. I haven’t thought through whether that would be fatal to discounts, but the notion makes me very uncomfortable
Has Kent Hovind Broken Any Laws?
This post is mainly about four letters. Here is a link to them. The first letter is one that was sent to three different tax professionals by Kent Hovind and the...
Tom Brady’s MVP Truck Even More On The Tax Implications
According to Forbes (And how could you do better?) Tom Brady gets about $7 million a year in endorsement income. Like I have said my knowledge of sports is subpar for an American male, but there is one thing that I have picked up. Part of Tom Brady’s image, or you might say his brand, is that he is a “There is no I in team” type of guy.
I was way too preoccupied with the repair regs and Kent Hovind to pay much attention to Deflategate, but I don’t think that it could have helped the Brady brand. So this class act with the truck might have been just the uptick his image needed. That’s the story I would have ready for AFH. Passing up that Chevy truck for a teammate was a shrewd move to keep the endorsements coming. But there is more.
Maybe Tom Brady is still loyal to the Dodge Dart and showing up at Chevy dealership, even to pick up a free truck, would be an embarrassment.